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On March 24 2025, the European Commission (EC) adopted the final draft Delegated Regulation setting out Regulatory Technical Standards (RTS) for subcontracting ICT services supporting critical or important functions under the...more
EU national supervisory authorities will collect the Register of Information (ROI) pursuant to the EU’s Digital Operational Resilience Act (DORA) from in scope financial entities in April 2025, with the reference date set as...more
What has happened: On 21 January 2025, the European Commission sent a letter to the Chair of the Joint Committee of the ESAs with its decision to reject the draft Regulatory Technical Standards (“RTS”) on subcontracting...more
The European Union’s Digital Operational Resilience Act (DORA) came into effect on January 17, 2025. DORA aims to harmonise rules concerning the provision of information and communication technology (ICT) services to...more
After a two-year implementation period, the EU Digital Operational Resilience Act (DORA) takes effect on 17 January 2025. DORA is part of the EU’s Digital Finance Package and aims to strengthen the financial sector’s...more
The EU Digital Operational Resilience Act (“DORA”) is due to apply from 17 January 2025. It is designed to ensure regulated financial entities can withstand and recover from technology issues such as cyber events and...more
The Digital Operational Resilience Act 2022/2554 (DORA) is a European regulation that will come into force on January 17, 2025. The regulation aims to strengthen the digital operational resilience of the financial sector...more
The European Supervisory Authorities have published a joint statement on the application of the EU Digital Operational Resilience Act. The ESAs emphasise that as DORA does not provide for a transitional period, it is...more
The European Commission’s adoption on 23 October 2024 of the two regulations (Regulations) supplementing the [the Regulation on digital operational resilience for the financial sector Publications Office (europa.eu)] (DORA)...more
This blog post focuses on how the EU’s Artificial Intelligence Act (“AI Act”) regulates generative AI, which the AI Act refers to as General-Purpose AI (“GPAI”) Models....more
The deadline is fast approaching for in-scope financial entities and their ICT service providers to conform to the EU’s new digital operational resilience regulation. With effect from 17 January 2025, a broad range of EU...more
Organisations that make international transfers of personal data have undergone significant challenges and changes over the last few years. With the invalidation of the Privacy Shield agreement in 2020 and the introduction of...more
Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more
In this blog post, we will focus on obligations that the European Union’s Artificial Intelligence Act (AI Act) sets for deployers, providers, importers and distributors regarding high-risk AI systems....more
The European Union (EU) Artificial Intelligence Act (AI Act), Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending...more
The Personal Information Protection Act ("PIPA") comes into full force on 1 January 2025. All organisations in Bermuda are expected to be in compliance with it by that date – time is running out! The Privacy Commissioner...more
With under six months to go until the European Union Digital Operational Resilience Act (DORA) becomes applicable on 17 January 2025, DORA implementation projects are running full steam ahead. DORA lays down uniform...more
The publication by the Joint Committee of the European Supervisory Authorities (ESAs) on (a) 17 July 2024 of the second batch of implementing materials and (b) 26 July 2024 of the sub-contracting of information and...more
The European Banking Authority and European Securities and Markets Authority have published joint guidelines on the suitability of members of the management body, and on the assessment of shareholders and members with...more
In December 2023, European Union (EU) lawmakers reached an agreement on the EU AI Act. Our article titled “An Introduction to the EU AI Act” focused on applicability, thresholds, timing, and penalties related to the EU AI...more
What is a Management Body? Under both DORA and NIS2, a management body can be a body with managerial and/or supervisory functions. The powers and structure of management bodies vary within the EU Member State, and managerial...more
The announcement in 2021 of the intention to implement new rules directly targeting the types of tech service provider relied on by most financial institutions may be a necessary corrective given the heavy market...more
The pace of new EU law continues unabated, with IoT, cyber security and digital services being key areas of activity. The BCLP Data Privacy & Security team is tracking EU law developments relevant to data and cyber security....more
A few weeks ago, on 24 September 2023, the Data Governance Act (Regulation (EU) 2022/868 of the European Parliament and of the Council of 30 May 2022 on European data governance) (“DGA”) came into force. The DGA aims to...more
1. European Court of Justice rules on access to electronic vehicle data system- The European Court of Justice („ECJ“) on 5 October 2023 ruled that car manufacturers cannot impose conditions on independent repairers‘ access...more